In 2024 the National Data Administration and other departments organised the Data Elements × competition, with tracks across twelve key industries and an emphasis on data compliance, licensing and security. On the surface it is a contest of scenarios and solutions; in substance it also tests whether participants can explain where their data came from, what licence covers it and how it will be used. For companies preparing to enter, compliance material matters as much as the solution itself.

How the competition is organised

Tracks are divided by industry, and assessment focuses on whether data fusion solves a real problem. Unlike a general innovation contest, the Data Elements competition expects a workable data foundation, which brings licensing and compliance to the surface early. A polished proposal loses points at review if the data source cannot be explained. Confirming that the data can be used is more practical than designing the model first.

Licensing boundaries for contest data

Using public, industry or third-party data in a contest requires confirming whether the licence covers contest use, whether display during demonstration and review is permitted, and whether later commercialisation is allowed. Contest use and commercial use are often conflated, and continuing to use contest data afterwards is a common risk point. Open licences for public data usually carry conditions; the fact that data can be downloaded does not mean it can be used without limit.

Personal information and trade secrets

Where contest materials contain personal information, de-identification or anonymisation is needed, together with confirmation of the processing basis. For data involving trade secrets, the rights holder’s explicit consent should be obtained and disclosure controlled during demonstration. A public demonstration at review may itself constitute external provision. For proposals containing customer data, a disclosure-risk assessment and a redacted version should be prepared before submission.

Ownership and post-contest use

The ownership of intellectual property in contest results, and the subsequent right to use data and models, should be checked in the participation agreement. Turning a contest proposal into a product often requires fresh data licensing; contest permission does not automatically extend. Contributions of team members and licences for third-party components should also be clarified before submission to avoid ownership disputes after an award.

The boundary after the contest

The end of the contest is not the end of the licence. Continuing to use contest data for product training, external demonstration or commercial analysis needs a separate legal basis. Public data provided by the organiser is usually used under an open licence; a company’s own data and third-party data depend on the original terms. A common post-contest error is to treat demonstration permission as long-term permission. Teams planning to productise a proposal should design a data-replacement plan at the contest stage and record the replacement. Where a partner’s data is involved, fresh consent is needed after the contest; an oral permission at team level is not enough. Review usually involves a live demonstration, so data isolation for the demonstration environment should be prepared in advance, and production data should not be brought into a public setting. Proposals involving minors’ data need an additional assessment of display and dissemination risk.

For contest data licensing and result arrangements, see our data compliance service and IP protection service; for cooperation agreement terms, see commercial contracts.


This article is based on public information about the Data Elements × competition organised by the National Data Administration and other departments in 2024. It is for reference only and does not constitute legal advice.

Geason Law Offices AI Industry Research Group | Reviewed by Ho Qianggao